On Oct. 30, 2015, the Centers for Medicare & Medicaid Services (CMS) released the final rule (PDF, 5.7MB) on the 2016 Medicare physician fee schedule, establishing Medicare’s payment policies for the coming year.
In its Sept. 8 comment letter (PDF, 165KB) on the 2016 Medicare Physician Fee Schedule Proposed Rule, the APA Practice Organization (APAPO) addressed areas that could impact reimbursement of psychological services, and CMS considered many of these comments when it developed its final rule.
Impact of Medicare’s payment formula for psychologists
CMS estimates the impact on Medicare reimbursement for clinical psychologists in 2016 to be 0 percent. Most other specialties also will see no impact on reimbursement next year based on the final rule.
However, since 2013, a mandatory sequestration cut has been imposed to all Medicare providers. This cut will reduce psychologist reimbursement by 2 percent in 2016. The Bipartisan Budget Act of 2015, signed by President Obama on Nov. 2, extended the 2 percent sequestration cut for Medicare providers through 2025.
In addition to losses caused by sequestration, Medicare payments to psychologists have declined significantly since 2001 because under the current formula Medicare pays more for higher-cost, technology-driven services with high overhead. APAPO continues to advocate for a legislative change in the Medicare payment formula so that psychologists are appropriately and fairly compensated for treating Medicare beneficiaries.
The Physician Quality Reporting System (PQRS)
CMS is not making changes to the claims-based reporting method for PQRS in 2016. Even so, the agency has stated in the past that claims-based reporting will be eliminated in future rulemaking.
Further, the reporting requirements for eligible professionals (EPs) for 2016 are the same as the 2015 requirements: EPs must report nine measures across three National Quality Strategy (NQS) domains and include at least one cross-cutting measure.
CMS finalized several new measures:
- No. 411: Depression Remission at Six Months – registry reporting only.
- No. 431: Preventive Care and Screening: Unhealthy Alcohol Use: Screening and Brief Counseling – registry reporting and measures group reporting and note: 431 is a cross-cutting measure.
- No. 414: Evaluation of Intervention for Rising Opioid Use – registry reporting only.
- No. 370: Depression Remission at Twelve Months – registry reporting being added.
- No. 131: Pain Assessment and Follow-Up: (will be available only through a new measures group).
- No. 173: Preventive Care and Screening: Unhealthy Alcohol Use – Screening.
- No. 285: Dementia: Screening for Depressive Symptoms (considered duplicative of measure 134).
- Cognitive Impairment Assessment Among At-Risk Older Adults.
- Documentation of a Health Care Proxy for Patients with Cognitive Impairment.
APAPO PQRSPRO is a CMS-qualified PQRS registry. To register, visit the PQRSPRO website.
Additional PQRS resources are available on the Quality Improvement Programs section of the Practice Organization’s Practice Central website.
Advanced care planning
CMS finalized its proposal to reimburse Medicare providers for Advance Care Planning services by a physician or other qualified health professional under new CPT codes 99497 and add-on code 99498. In APAPO’s comment letter, we applauded CMS for recognizing the importance of having health professional discuss topics such as advance directives and explained psychologists' education, training and experiences qualifies them to provide advance directive services. However, in the final rule, CMS was not clear on which nonphysician providers will be reimbursed for these services. APAPO has contacted CMS regarding this issue and continues to advocate for psychologists to have access to these codes.
CMS will not apply the value-based modifier for psychologists and certain other nonphysician practitioners. Instead, the agency will transition these providers directly to the Merit-Based Incentive Payment System (MIPS), which will occur after 2019. APAPO members can learn more about MIPS in Spring/Summer 2015 issue of Good Practice magazine (PDF, 2.2MB).
CMS is still considering comments, including those made by APAPO, for proposed collaborative care models for beneficiaries with common behavioral health conditions. The agency is seeking further input from primary care providers before proposing a new model. Regarding chronic care management and transitional care management services, CMS stated that it will take APAPO and other stakeholder comments into consideration if it decides to develop proposals in a future rulemaking.
Members with questions may contact the Government Relations Office for APAPO by email or by phone at (202) 336-5889.